Photo Verification (Current and Future Use)

To maintain an authentic community, we review profile photos to confirm they comply with our guidelines. 

• Right Now: Photo verification is handled manually by our moderation team or through basic visual filters to ensure completeness. 

• In the Future: We intend to introduce automated photo and video selfie verification. When we roll this feature out, we will ask for your explicit consent to use facial characterization technology to compare your live selfie against your profile photos. We will update this policy and provide clear in-app notice before activating this technology.

  
  

Why We Collect and Use Information

We collect, use, and process personal information to operate the Platform and deliver its core features. This includes creating and managing accounts, authenticating users, securing access, displaying profiles, enabling matching and communication features, generating compatibility and insight-related functions, highlighting recommended local venues or volunteer events, supporting safety tools, and responding to support requests.

We also use personal information to review reports, investigate suspected abuse or fraud, prevent multiple account creations by banned users, moderate content and accounts, prevent impersonation and unlawful conduct, improve product performance and reliability, troubleshoot technical issues, send service-related communications, enforce our Terms, and comply with legal obligations.

Where you have separately chosen to receive optional updates, newsletters, promotions, or similar communications, we may also use your contact information for those purposes. You may unsubscribe from optional promotional communications at any time without affecting core service-related notices.

Consent and Important Choices

Canadian privacy law requires consent to be explicit, transparent, and meaningful. To support that, we want users to understand the main elements of our data practices: what information we collect, why we use it, when we share it, and the consequences that matter.

Some information is necessary for the Platform’s core service to function as intended. For example, birth-related and profile-related information may be required for compatibility or astrology-related features, and location-related information may affect local matching or discovery. If you choose not to provide certain information, some features may be unavailable or may not function effectively.

We seek to rely on express consent where appropriate, especially when information is sensitive, when use is not obvious from context, or when optional features or communications are involved. Marketing or optional updates will not be bundled with acceptance of core legal terms.

You may withdraw consent to certain collections, uses, or disclosures, subject to legal or contractual restrictions and reasonable notice. In some cases, withdrawing consent may limit or prevent the use of certain Platform features or may require account closure where the information is necessary for the service to function.

Insights, Matching, and Automated Features

Scuba may use personal information, including birth-related details, profile information, preferences, activity data, and related inputs, to generate compatibility insights, astrology-related outputs, profile recommendations, and other personalized features. These features may involve automated processing, profiling-like analysis, algorithmic systems, or AI-assisted tools.

These outputs are intended to support Platform functionality and user experience. They are not guarantees of compatibility, identity, truthfulness, safety, or relationship outcomes, nor are they medical, psychological, legal, or professional advice. Automated or AI-assisted outputs may be incomplete, inaccurate, biased, unavailable, or unsuitable for a particular purpose.

Photos and Metadata

When users upload profile photos, the Platform may remove certain metadata before upload or storage, including through on-device or system-level handling where available. However, no technical process is infallible, and complete removal of all embedded metadata cannot be guaranteed in every circumstance. Users should avoid uploading photos or other content containing sensitive embedded information they do not want disclosed.

Chats, Reports, Safety, and Moderation

We may collect, access, review, preserve, and use information associated with chats, reports, blocks, moderation flags, complaints, and related account activity for safety, abuse prevention, fraud detection, impersonation review, legal compliance, and enforcement purposes.

The Platform may use text-based review tools, keyword flagging, automated detection methods, AI-assisted moderation, human review, or a combination of these methods to detect, assess, or address potentially harmful or prohibited activity. We do not guarantee constant monitoring, but users should understand that communications and safety-related records may be reviewed or preserved where reasonably necessary for safety, security, moderation, legal, or operational reasons.

When We Share Information

We do not sell your personal data to data brokers for cash. We may, however, share personal information with service providers that help us operate the Platform, including providers of hosting, cloud storage, authentication, monitoring, analytics, communications delivery, moderation support, diagnostics, and related technical infrastructure.

We may also share personal information where reasonably necessary to investigate abuse, fraud, harassment, impersonation, intellectual property complaints, security incidents, or unlawful conduct. We may disclose information where required by law, court order, legal process, regulatory request, or where reasonably necessary to protect the rights, safety, property, or security of users, third parties, or Align.

We may also disclose personal information as part of a merger, financing, reorganization, acquisition, sale, or other business transaction, subject to applicable legal requirements and appropriate protections where required.

We do not sell personal information as part of the current Scuba operating model. If that practice materially changes, we will update this Privacy Policy and provide additional notice where required by law.

Service Providers, Referrals, and External Services

We use third-party service providers to help us run the Platform. These may include providers of cloud hosting, storage, authentication, security, monitoring, email delivery, analytics, diagnostics, moderation support, or related services. Those providers may process personal information on our behalf for the purposes described in this Privacy Policy and as otherwise permitted by law.

The Platform may also display or refer users to third-party venues, events, promotions, sign-in tools, activities, offers, or external pages. If you click through, register, book, purchase, or otherwise interact with a third-party service, that third party may collect information directly from you under its own privacy practices. We may receive limited referral, attribution, campaign, or transaction-related information in connection with those interactions, and we may receive referral or promotional consideration from some third-party arrangements.

Cross-Border Storage and Processing

While our primary area of operations is Canada, some personal information may be stored or processed outside Canada, including in the United States, because certain third-party service providers or technical infrastructure partners we use to operate the Platform may be located or operate in other jurisdictions. When personal information is processed in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, law enforcement, or regulatory authorities there.

We take reasonable steps to use service providers that provide safeguards appropriate to the sensitivity of the personal information and to protect personal information through reasonable contractual, technical and organisational measures.  

Your Privacy Rights and Choices

Subject to applicable law, you may request access to your personal information, request correction of inaccurate information, request deletion of personal information, withdraw consent to certain processing activities, or opt out of optional promotional communications. We may require reasonable verification of identity before responding to a request.

Some requests may be limited by law, by the rights or privacy of other users, by safety or fraud-prevention needs, by legal retention duties, or by the technical realities of backups and archived records. For example, where information relates to reports, moderation activity, chats involving other users, or legal disputes, we may limit deletion or access in whole or in part.

Privacy requests, complaints, or questions may be directed to our Privacy Team using the contact details below.

Retention, Deletion, and Inactive Accounts

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including operational, safety, legal, dispute-resolution, fraud-prevention, and security purposes. 

When you request deletion or choose to close your account, your profile immediately becomes invisible to other members. We typically delete or permanently anonymize your data within 90 days, unless it must be retained longer to investigate safety reports, resolve active disputes, prevent platform fraud or comply with legal retention duties or where stored for a longer period based on your express consent or for any other legitimate reason. Some residual information may remain for a limited period in backups, logs, compliance archives, investigation files, or records retained for legitimate legal or operational reasons.

Accounts that remain inactive for an extended period, including approximately one continuous year, may be deleted, anonymized, or otherwise removed in accordance with our retention practices.

Deceased Users and Authorized Representatives

If we receive notice that a user has died, we may suspend, restrict, delete, or otherwise handle the account in accordance with applicable law, our internal policies, and privacy, safety, evidentiary, and legal considerations.

Requests from an executor, estate trustee, legal representative, family member, or other person claiming authority may require documentary proof reasonably satisfactory to us, such as a death certificate, probate materials, certificate of appointment of estate trustee, proof of identity, or other supporting information reasonably necessary to assess the request.

We are not required to provide unrestricted access to a deceased user’s account, messages, or content merely because someone claims to be a beneficiary, family member, or representative. Disclosure may be limited or refused where required or appropriate for privacy, contractual, safety, evidentiary, or legal reasons.

Age Restrictions

scuba is not intended for individuals under 21 years of age. We do not knowingly permit anyone under 21 to create an account or use the Platform.

If we learn that personal information has been collected from a person under 21 in connection with the Platform, we may take immediate steps to deactivate the account and delete or restrict associated information as appropriate.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make changes, we will post the revised version with an updated effective date, and we may provide additional notice in the app, on the website, or by email where appropriate.

If a change materially affects how we collect, use, or disclose personal information, we may seek renewed consent where required by applicable law. Meaningful consent is an ongoing obligation, not a one-time formality.

Contacting Us About Privacy

If you have questions, concerns, complaints, or requests regarding this Privacy Policy or our handling of personal information, you may contact us at:

Privacy Team
Align Dating Inc.
Email: privacy@scubatheapp.com
Mailing Address: 375 University Avenue, Suite 3333, Toronto, ON. M5G2J5, Canada.